Privacy Policy

This Privacy Policy (the “Privacy Policy”) is effective as of June 19, 2017.

Winston Products LLC respects your privacy and is committed to protecting it through our compliance with the Privacy Policy.

This Privacy Policy describes the practices with respect to information collected and received through our websites, mobile websites, mobile applications and similar content (“Sites”) that are owned, operated, and/or controlled by Winston Products, LLC or any of its subsidiaries, parents, or affiliated companies (collectively, “Winston Products”). This includes the types of information collected, how it is used, and with whom it is shared. This Privacy Policy is expressly incorporated into our Terms of Use (the “Terms”), to which you consent to by use of the Sites. Also, please be advised that certain capitalized terms used in this Privacy Policy may be defined in the Terms.

This Privacy Policy applies only to information we collect from the Sites and does not apply to any other business activity of Winston Products. If you do not agree to the terms of this policy and do not consent to the collection, use and maintenance of information as described in this Privacy Policy, you should leave the Sites immediately.

By submitting personal information to Winston Products and/or its agents, you agree that Winston Products may collect your personal information and you consent to the use, disclosure and transfer of your personal information in accordance with this privacy policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified herein at any time by contacting Winston Products as provided below. If you refuse or withdraw your consent, you acknowledge that Winston Products may not be able to provide you or continue to provide you with access to the Sites or other information/services which may be of value to you.

We reserve the right to revise this Privacy Policy at any time. When we do, we will give you notice of the revised Privacy Policy by posting the revised Privacy Policy on the Sites and by revising the “effective date” at the top of the Privacy Policy. You are responsible for regularly reviewing the current policy.

PRIVACY OF CHILDREN

We do not intentionally collect personal information from users of the Sites who are under the age of thirteen (13). If you are under 13, do not provide any information on the Sites, register on the Sites, use any interactive or public comment features of the Sites, or provide any information about yourself on the Sites, including your name, address, telephone number, email address, or any screen name or user name you may use. If we become aware that a user of one or more of the Sites is under the age of 13 and has provided information to us (e.g., joined a mailing list, entered a sweepstakes, contest or other promotion, etc.) using the Sites, we will remove that child’s personal information from our files. We may use the information to provide notices to the parents of users under the age of 13 where that may be necessary. If you believe we might have any information from or about a child under 13, please contact us at privacy@winstonproducts.us.

THE INFORMATION WE COLLECT AND HOW WE USE IT

We collect and store “personal information” and “automatic information.”

Personal Information. Personal information is information that tells us who you are, such as your first and last name, your postal address and zip code, your e-mail address, your telephone number, your hobbies and interests, and/or information regarding your purchases.

We may collect information from you if you register with one or more of the Sites, sign up for a newsletter or mailing list, enter a sweepstakes or contest, submit a rebate or coupon request, or otherwise voluntarily provide information to us (e.g., by submitting your email by contacting us via our “Contact Us” webpage or in connection with ratings, reviews, requests for advice, suggestions, testimonials or any user generated content, such as photographs and/or videos).

Winston Products may use collected personal information internally, separately, or in combination with pre-existing information, for the following purposes:

To establish and conduct commercial relationships, including to process purchases or other transactions and to conduct or administer other transactions that you may engage in with Winston products on or through the Sites;

To conduct or administer contests, sweepstakes or other promotions in which you have participated;

To contact you and to respond to any communications that you may have had with us;

To troubleshoot problems with the Sites;

To customize your experience or homepage on the Sites;

To develop and manage our business and operations;

To enforce our Terms or comply with the Privacy Policy;

To detect and protect Winston Products and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with Winston Products’ policies and contractual obligations;

To engage in business transactions involving Winston Products;

As permitted by, and to comply with, any legal or regulatory requirements or provisions;

To access, preserve, disclose and use your personal information contained in your account, all Submissions (as defined in the Terms), all communications to and from you, all information relating to your use of the Sites, if Winston Products is required to do so by law or legal process or if Winston Products determines, in its sole discretion, that such action is necessary to protect the rights of Winston Products, third parties, and other users of the Sites or for purposes of responding to your request for customer service; or

For any other purpose to which you consent.

Automatic Information. Automatic information is information automatically collected by our webserver (which may be hosted by a third party), or third party services (such as Bazaarvoice), that your web browser makes available whenever you visit the Sites. As you navigate through and interact with the Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (a) details of your visits to the Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Sites, and (b) information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties.

The technologies we use for this automatic data collection may include:

Cookies: Like many websites, Winston Products uses “cookies” to maintain a record of your visit to the Sites. A cookie is a small text file that is transferred by a web server and stored on the hard drive of your computer or mobile device. It can only be read by the server that sent it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided Winston Products with personal information.

Cookies help us to improve the Sites, and to deliver more personalized service by enabling us to estimate audience size and usage patterns; to store information about your preferences; to speed up your searches and to recognize you when you return to the Sites.

Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of the Sites or receive certain information/services.

Flash Cookies. Flash cookies track a person’s Internet use across websites and are not deleted or controlled by users in the same manner as standard HTML Cookies.

Web Beacons. Pages of the Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

In addition to these tools, for each visitor to the Sites, our webserver automatically recognizes and/or collects (where possible) certain information, such as your domain name, IP address, type of computer, type of web browser, screen size and characteristics (e.g., color, resolution), and operating system, and the city, state and/or country in which you are located. We may also collect information regarding your Internet browsing history (e.g., the site you visited before accessing the Sites, the search engine and search terms that you used, and information about your previous visits to the Sites), the length of your visit, the pages you viewed, your Internet service provider, the language settings on your computer, and certain software (e.g., Java support).

We may use such information for purposes of system administration, to improve the design and content of the Sites, to speed up searches, and/or to enable us to personalize your Internet experience. We may also use such information in the aggregate to analyze the Sites usage and/or to assess the traffic to the Sites.

IP ADDRESSES

An IP address is a computer’s numeric address, by which it can be located within a network. Winston Products may record your IP address when you visit or use services or features on the Sites. We may use your IP address for the purposes noted above, and also to help diagnose problems with our server and administer the Sites. We may also use your IP address to identify you when Winston Products feels it is necessary to enforce compliance with this Privacy Policy or the Terms, or to protect the Sites, systems, information, employees, service providers, business partners, users, customers and others.

DISCLOSURE

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may transfer and otherwise disclose your personal information and automatic information to third parties that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

Without limiting the generality of the foregoing, we may transfer or otherwise disclose such information to third parties (a) for their marketing purposes, (b) that perform services on behalf of Winston Products, (c) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Winston Products’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Winston Products about the Sites users is among the assets transferred, (d) to meet any applicable law, regulation, legal process or enforceable governmental request, (e) to protect and defend the rights or property of Winston Products or its affiliated companies, (f) to identify, contact and/or bring legal action against someone who may have breached our Terms, (g) to act to protect the interests of the Sites, users, or others as we deem necessary (h) to fulfill the purpose for which you provide it, and/or (i) with your consent.

PROTECTION OF INFORMATION

To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of information, Winston Products uses physical, technological, and administrative procedures to protect the personal information collected from loss, unauthorized access, modification, disclosure, or other misuse.

Nevertheless, Internet transmissions are never completely private or secure, and you understand that any messages or information you send to the Sites may be read or intercepted by others. As a result, we do not ensure, warrant, or guarantee the security or integrity of such information. We will not be responsible for disclosure of any information due to errors in transmission or the unauthorized acts of third parties. If you have any questions about the security of personal information collected by Winston Products, please contact: privacy@winstonproducts.us.

You should also be aware that certain aspects of the Sites are not confidential and are available for public viewing. For example, any Submissions that you may post to any publicly available features of the Sites are not confidential and may be viewed by others. By making personal information publicly available where the Sites allow, you consent to such publication by Winston Products, its service providers, and/or agents. Please refer to the Terms for additional provisions relating to Submissions that may apply to you.

ACCESSING AND CORRECTING PERSONAL INFORMATION

Winston Products takes reasonable steps to ensure the personal information it holds is accurate, complete, and current. Upon your written request, subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal information and give you access to that information. Additionally, if you have any questions relating to our privacy practices or procedures, or if you believe that the personal information that we hold about you is not accurate, complete, or current, you may contact us as set forth below. If you are able to establish that the information is not accurate, complete, or current, we will take reasonable steps to correct the information.

If you would like to review the personal information that we have collected about you through the Sites, please send your name, street address, telephone number and e-mail address to us by regular mail to the following address:

privacy@winstonproducts.us

We will send you the personal information that we have collected about you online. If you would like to correct any factual errors, please note such correction and send them to us at the same address listed above so that we may make the corrections that you have requested.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits users of the Sites that are California residents to request a notice identifying the categories of personal information we share with third parties for their direct marketing purposes. To make such a request, please submit a written request, specifying that you would like a “California Privacy Notice,” to the following address:

privacy@winstonproducts.us

CHOICE AND OPT-OUT PREFERENCES

You can choose not to provide any personal information if you do not want it collected, used, and disclosed as described in the privacy policy. Winston Products does not collect your personal information unless you choose to provide it. Also, if at any time you prefer not to receive further email communications from Winston Products (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in our broadcast e-mails.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise this Privacy Policy at any time. When we do, we will also revise the “effective date” at the top of this Privacy Policy. You are responsible for regularly reviewing the current policy. The most current version of the Privacy Policy can be reviewed by clicking on the “Privacy” or “Privacy Policy” hypertext on our Sites. Your continued use of the Sites after we post any revisions constitutes your agreement to any such revisions. If any such revisions are unacceptable to you, do not access the Sites and do not submit any information to us.

THIRD PARTY ANALYTICS

Winston Products uses automated devices and applications provided by third parties, such as Bazaarvoice, to evaluate usage of our products, Sites, and/or other service, and we may add or change these automated third party services from time to time. We use these tools to help us improve our products, services, and user experiences. These third parties may use cookies and other tracking technologies which collect information to perform their services. We do not share personal information that we collect directly with these third parties. These third parties, however, may collect personal information directly through the use of cookies and other tracking technologies. For an explanation of the information collected by these third parties and their applicable privacy policies, please go to the Bazaarvoice Privacy Policy. These third parties use cookies. To delete, disable and opt-out of cookies used by Bazaarvoice, please go to the opt-out section of the Bazaarvoice privacy policy.

THIRD PARTY TRACKING

Winston Products collects transactional information and browse behavior on our website. Winston Products may use such information to offer you recommendations for products and services that are relevant to your interests. Winston Products uses the services of trusted third parties to offer you meaningful recommendations during the online experience. Winston Products shares IP address, unique id number, and shop and browse behavior with the third party service provider on an aggregate basis but does not share personal information for these purposes.

Winston Products also works with trusted third parties that use tracking technologies to serve advertisements on our behalf across the internet. these companies may use cookies and tracking pixels to collect non-personally identifiable information such as items viewed, items added to your shopping cart and items purchased during your visits to our website in order to help show advertisements on other websites likely to be of interest to you. if you would like more information about this practice or to opt-out of this use of your anonymous information, please visit http://www.networkadvertisi[ng.org.

Mobile Applications

Winston Products may, from time to time in our sole discretion, offer users the ability to download and use mobile applications. By downloading and/or using these mobile applications, you agree to any applicable terms for using the applications (which will be provided when you download such applications). You may be required to provide personal information in order to use the mobile application, including your first name, last name, email and password. You will have the option of providing other personal information in connection with your use of the mobile application (e.g., your picture, your physical location, your birthday, etc.).

If you have granted permission through your device to allow us to collect location information, we may obtain pinpointed physical location information from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire pinpointed location information from your device through your device settings, although Winston Products does not control this process. The mobile application may use the geo-location features of that application (GPS or network-based) to support your use of location-based tools such as locating stores or products near you.

Also, our mobile applications may interact with social media sites (e.g., Facebook) and import your social media information, including your contacts, into the application for the purpose of allowing you to invite others to download the application or participate in certain activities. If you agree to connect our mobile applications with your social media information and to share information, you grant Winston Products permission to access and use such information for such purposes provided in this Privacy Policy. You further represent and warrant that you have the right to share and all such information for the purposes provided in this paragraph and such use does not violate the rights of any third party. Please note that Winston Products does not, in any way, control the information that your social media accounts collect from you.

You will have the option to opt-out partially or completely from any of our mobile applications or withdraw any permission granted to Winston Products.

LINKS TO OTHER WEBSITES

While you are using the Sites, you may be linked or directed to other third party sites outside of the Sites that are beyond our control. Each of these third party sites may have a privacy policy that differs from ours. These links may take you to sites of advertisers, sponsors, and co-branding partners. It is your responsibility to review the privacy policies of these sites. We are not responsible for any actions or policies of such third parties.

CONTACT INFORMATION

We welcome your comments regarding this Privacy Policy. If you have questions or concerns regarding this Privacy Policy, please contact us by U.S. mail at: